Forced Labor Enforcement Efforts Expanded to PVC Products

U.S. Customs and Border Protection (CBP) has added polyvinyl chloride products to its forced labor enforcement efforts.

The forced labor laws require CBP to presume that all goods manufactured wholly or in part in hotspot locations globally are made with forced labor and therefore prohibited from entry into the U.S. This presumption can be overcome if the importer can show that the forced labor due diligence is not applicable to the goods.

For listed entities, the presumption may be overcome if:

• the importer provides “clear and convincing evidence” to CBP that the goods were not made with forced labor; and,

• the importer has fully complied with due diligence guidance and regulations and responded to all related CBP inquiries.

As a result, CBP is now detaining PVC products such as vinyl flooring under the forced labor law and asking importers to trace these items back to their originating chemicals such as chlorine, carbon, and ethylene. Other products made using PVC include, but are not limited to:

• Vinyl flooring

• Footwear

• Some clothing

• Bookbags

• Furniture

Companies should map their supply chains and ensure their supply chain partners are maintaining sufficient records to prove forced labor due diligence and compliance.

For more information about how to automate due diligence and transaction traceability requirements and supply chain mapping, get in touch with our experts.